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EFTA00009924.pdf
This document is an email chain from November 2020 between an Assistant United States Attorney (SDNY) and Bureau of Prisons (BOP) staff regarding the delivery of a laptop and hard drive to the Metropolitan Detention Center (MDC). The equipment was intended for inmate Ghislaine Maxwell (Reg. No. 02879-509) to review legal discovery materials produced by the US Attorney's office. The emails coordinate the logistics, timing, and specific location (East Building, 29th St) for the drop-off.
EFTA00009920.pdf
This document is an email chain between Ghislaine Maxwell's defense attorney, Bobbi Sternheim, and the US Attorney's Office (SDNY) regarding conditions at the Metropolitan Detention Center (MDC) in November 2020. Sternheim requests Maxwell be moved to an interior cell due to reports that the NYC Dept. of Design & Construction would be shutting off heat and water overnight for repairs. The Assistant US Attorney denies the request, stating that temperatures are being monitored and remain within BOP policy limits, and asserting that Maxwell's current placement is appropriate for safety and security.
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This document is a page from the sentencing transcript of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on August 22, 2022. The presiding judge rejects Maxwell's complaints about her treatment at the MDC, noting she had ample resources for legal preparation. The judge criticizes Maxwell for a pattern of dishonesty regarding finances and deflection of blame, noting that while she acknowledged the victims' suffering, she failed to accept personal responsibility.
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This document is page 83 of a court transcript from the sentencing phase of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on August 22, 2022. The defense counsel is arguing for mitigation, highlighting Maxwell's age (over 60), lack of prior criminal history, and positive behavior while incarcerated at the MDC, specifically noting her move from solitary confinement to general population where she teaches English and GED classes to other inmates. The text acknowledges she is being sentenced for 'terrible conduct' but argues she poses no recidivism risk and has been an asset to her prison unit.
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This document is a transcript page from the sentencing hearing of Ghislaine Maxwell, filed on August 22, 2022. The Court lists various documents reviewed for sentencing, including support letters for Maxwell, a forensic psychiatric evaluation, a letter from an MDC inmate regarding Maxwell's tutoring, and numerous victim impact statements from individuals including Annie Farmer, Virginia Giuffre, and Sarah Ransome. Counsel for both sides confirm the record of submissions before the court.
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This legal document, filed on behalf of Ms. Maxwell, details her alleged mistreatment while in custody at the MDC. The filing outlines several issues, including invasive physical searches that increase her COVID-19 risk, severe deprivation of adequate and nutritious food leading to significant weight loss and health problems, and sleep deprivation due to constant checks with flashlights. These conditions are presented as negatively impacting her health and her ability to prepare for her legal defense.
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This document is page 3 of a legal filing by attorney Bobbi C. Sternheim on behalf of Ghislaine Maxwell, dated December 7, 2020. The letter argues that Maxwell is facing unduly harsh conditions, including solitary isolation, as a result of the Bureau of Prisons' incompetence and embarrassment over Jeffrey Epstein's suicide. Sternheim asserts that Maxwell is an 'exemplary detainee' and calls for Warden Tellez to address the concerns regarding her confinement, which are allegedly interfering with her legal defense.
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This legal document, filed by the law office of Bobbi C. Sternheim on behalf of Ms. Maxwell, argues against the restrictive conditions of her confinement at the Metropolitan Detention Center (MDC). The filing contends that these measures, including constant surveillance and repeated searches, are an overreaction to the BOP's failure to prevent Jeffrey Epstein's death, rather than being based on any specific risk posed by Maxwell. The document also raises concerns about Ms. Maxwell's exposure to COVID-19 and the erasure of her legal emails, quoting then-Attorney General William Barr's stated interest in ensuring she makes it to trial.
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This legal letter, sent by attorney Bobbi C. Sternheim on behalf of her client Ghislaine Maxwell to Judge Alison J. Nathan, formally complains about Maxwell's harsh and restrictive conditions at the Metropolitan Detention Center (MDC). The letter refutes a previous communication from MDC staff, detailing issues such as significant weight loss, isolation, constant surveillance, and a recent quarantine that hindered her defense preparation. Sternheim renews the request for the MDC Warden, Heriberto Tellez, to respond directly to the Court and justify these conditions.
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This court order, dated December 2, 2020, addresses the individualized detention conditions of Ms. Maxwell, noting concerns about the lack of redress for serious conditions. It directs Warden Tellez to provide a first-hand accounting to the Court and counsel regarding these conditions. Additionally, MDC legal counsel is ordered to submit a letter to the Court by December 4, 2020, for review to determine if further information is needed.
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This document is the second page of a filing from the United States Attorney's Office regarding the conditions of confinement for a defendant (implied to be Ghislaine Maxwell based on the case number) at the MDC. It details the schedule for legal calls, discovery review, and isolation, asserting that the defendant has more access than other inmates and that the Government is actively communicating with defense counsel regarding any concerns.
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This document is page 3 of a court filing (Case 1:20-cr-00330-AJN) filed on November 6, 2020, likely in the prosecution of Ghislaine Maxwell. The Government argues regarding discovery deadlines, agreeing to a laptop for the defendant to review evidence at the MDC but refusing early disclosure of witness lists (Giglio/Jencks material) seven months before trial. The text details upcoming discovery productions, specifically mentioning thousands of images/videos from Epstein's electronic devices, portions of seized iPads and an iPhone, and documents from the FBI's Florida files.
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This is page 3 of a legal filing (Case 1:20-cr-00330-AJN, likely US v. Ghislaine Maxwell) dated November 6, 2020. The Government argues against the immediate production of witness lists (Giglio/Jencks material), stating it is premature seven months before trial. The document details an upcoming 'sixth discovery production' due November 9, 2020, which includes thousands of images/videos from Jeffrey Epstein's electronic devices, portions of his iPads and iPhone, and FBI Florida files.
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This document is the final page of a Government filing (dated Oct 30, 2020) regarding the detention conditions and discovery process for the defendant (Ghislaine Maxwell) at the Metropolitan Detention Center (MDC). The Government argues against the need for a court order regarding MDC issues, citing that protocols are already in place for passing papers, COVID-19 safety (Plexiglas barriers), and laptop viewing. The filing asserts that the defendant has access to discovery materials for approximately 13 hours a day—more than any other inmate—and details technical efforts to resolve file viewing issues mentioned in a footnote.
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This document is page 6 of a legal filing dated October 23, 2020, addressed to Judge Alison J. Nathan from Ghislaine Maxwell's defense team. The text details significant ongoing technical failures at the Metropolitan Detention Center (MDC) regarding Maxwell's ability to access discovery materials on provided hard drives. Despite multiple letters and conference calls between August and October 2020, the Government and MDC IT staff failed to provide a functional computer or readable files, severely impairing Maxwell's ability to prepare her defense.
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This is page 3 of a court order (Case 1:20-cr-00330-AJN) filed on August 25, 2020, concerning Ghislaine Maxwell. The Court denies Maxwell's request for an order against the BOP regarding her surveillance and confinement conditions, citing security concerns and deference to prison administrators. However, the Court orders the Government to provide written status updates every 90 days regarding any changes to her conditions to ensure she can participate in her defense.
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This is the final page (6 of 6) of a legal filing submitted on August 10, 2020, to Judge Alison J. Nathan by attorneys Mark S. Cohen and Christian R. Everdell on behalf of Ghislaine Maxwell. The document requests that Maxwell be released to the general population within the MDC (Metropolitan Detention Center) and be granted increased access to a computer terminal to review discovery materials for her defense.
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This document is the final page of a legal motion filed on August 10, 2020, by attorney Christian R. Everdell on behalf of his client, Ms. Maxwell. The motion requests that the court, presided over by Judge Alison J. Nathan, grant Maxwell's request to be released into the general population of the MDC and be given increased computer access to review discovery materials for her defense.
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This document is a letter to Judge Alison J. Nathan arguing that the conditions of Ms. Maxwell's confinement at the MDC violate her Sixth Amendment rights by severely restricting her ability to review discovery materials. The defense contends that the BOP's proposed three-hour daily window for reviewing documents is insufficient given the volume of evidence and conflicts with necessary time for hygiene and exercise.
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This legal document, part of a court filing from July 13, 2020, argues against a defendant's motion for temporary release. It cites two prior rulings from the Southern District of New York (involving Gonzalez and Eley) to establish that release is not necessary, especially when trials are not imminent. The document further contends that the detention center (MDC) has been responsive and accommodating to defense counsel's requests for client access, undermining the argument that release is required for defense preparation.
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This document is page 17 of a court filing (Document 22) in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 13, 2020. The text argues against granting bail, citing an 'extraordinary risk of flight' and rejecting the defendant's claim that detention at the MDC prevents adequate preparation for defense. The filing cites numerous precedents (Tolentino, Adamu, Brito, etc.) where bail was denied despite access-to-counsel restrictions, distinguishing the current case from *United States v. Stephens*.
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This document is page 15 of a Government memorandum filed on July 13, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The prosecution argues against granting bail, citing that the MDC is adequately handling COVID-19 risks and referencing legal precedents where bail was denied despite the pandemic. A footnote emphasizes the Government's position that the defendant has the financial means to flee the country and that pandemic travel restrictions would not prevent her flight.
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This document is page 22 of a legal filing dated May 27, 2021, arguing against Ghislaine Maxwell's renewed motion for release. The text asserts that Judge Nathan did not abuse her discretion in detaining Maxwell as a flight risk and highlights Maxwell's extensive access to discovery materials via computers (13 hours/day) and legal counsel via video calls (25 hours/week) at the MDC.
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This legal document, part of a court filing, refutes claims made by an inmate named Maxwell regarding her conditions of confinement at the MDC. It distinguishes her situation from a case involving Tiffany Days, who experienced sewage flooding at a different facility (the MCC), and argues there is no evidence of such issues at the MDC. The document also counters Maxwell's claim of being in "solitary confinement" by detailing her daily access to a day room and various amenities for thirteen hours.
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This page from a legal filing (Case 21-770) argues that Judge Nathan acted within her discretion regarding Ghislaine Maxwell's confinement at the MDC. It asserts that Maxwell failed to provide evidence that MDC protocols interfered with her trial preparation. The document dismisses Maxwell's complaints about conditions—specifically regarding undrinkable water, inadequate food, audio recording of legal visits, and sewage overflows—as bare assertions without evidence.
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